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PATRICK v. COMMISSIONER

Docket Nos. 26419-96, 26420-96.

75 T.C.M. 1629 (1998)

T.C. Memo. 1998-30

Wayne L. Patrick v. Commissioner. Brian J. Patrick v. Commissioner.

United States Tax Court.

Filed January 26, 1998.

Attorney(s) appearing for the Case

Joseph Falcone, Southfield, Mich., and Brian H. Rolfe, for the petitioners. Mark L. Hulse and Laurence D. Ziegler, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

LARO, Judge:

On October 4, 1996, respondent issued separate notices of deficiency to Brian J. Patrick (Brian) and Wayne L. Patrick (Wayne) based on their failure to include in gross income the distributions from a qualified profit-sharing plan and on Wayne's failure to include in gross income the distributions from an individual retirement account (IRA). Respondent determined deficiencies and additions to tax as follows...

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